Publication - Consultation analysis

Planning Scotland's Seas: Scotland's National Marine Plan. Consultation Response Analysis Report

Published: 2 May 2014
Part of:
Marine and fisheries

Planning Scotland’s Seas: Scotland’s National Marine Plan was published for consultation in July 2013. Independent analysis of all written responses to the consultation has been undertaken and is presented in this report.

Planning Scotland's Seas: Scotland's National Marine Plan. Consultation Response Analysis Report


Chapter summary

  • A large majority of those responding considered the NMP should incorporate spatial information for Sectoral Marine Plans ( SMPs) with comments that the NMP needs to lead this system and that it needs to provide an overview of spatial areas identified in SMPs. Furthermore, this was seen as helping to integrate policies and interactions between the offshore renewable sector and the marine environment.
  • There were suggestions from some respondents for the SMPs to be seen as background information to the NMP rather than as stand-alone documents.
  • There were some requests for additional information within the NMP, for example, an explanation of the nature of the spatial information provided or how data management and decision making at a sectoral level would interact with marine planning.
  • The small number opposed to spatial information for SMPs being incorporated within the NMP focused primarily on the need for the NMP to signpost and provide links to relevant documents.
  • There were also requests for greater consistency between land use planning and marine planning in terms of offshore renewables and the need for greater links between NPF3 and the NMP. There were also comments that there needs to be better integration between offshore and onshore renewables, and integration of land use and marine planning systems.
  • There were a small number of comments relating to the need to ensure that sustainability is taken into account, and the cumulative impact of developments upon the environment; as well as reference to maintaining a balance between new offshore developments and existing sectors.
  • The need for consultation across all interested stakeholders was highlighted; as was the need for more research to be undertaken.

12.1 The Draft NMP noted that Scotland's sea area has an estimated 25% of Europe's offshore wind and tidal resource and 10% of the wave resource; with the Scottish Government committed to building a globally competitive offshore renewables industry. Offshore renewables have a key role to play in Scotland's targets for electricity production.

Spatial information for Sectoral Marine Plans ( SMPs)

12.2 Respondents were asked:

Question 23: Should the NMP incorporate spatial information for Sectoral Marine Plans?

12.3 Fifty-six respondents provided an answer ( table 12.1). Most of those providing a definitive response, i.e. 'yes' or 'no', were positive. Thirty agreed, 3 disagreed and 16 provided qualified agreement. Those who were not definitive provided commentary that was not directly relevant to this specific question, for example, suggested changes to wording in the draft policies.

Table 12.1 Question 23: Should the NMP incorporate spatial information for Sectoral Marine Plans?

Respondent group Yes No Yes qualified Neither 'yes' or 'no'
Individuals (16) - - - 4
Academic / scientific (7) 2 - - 1
Aquaculture (5) - - - -
Energy (12) 6 1 1 1
Environment / conservation (9) 6 - - -
Fisheries (13) 3 - - -
Historic / Heritage (5) - - 2 -
Industry / transport (9) 2 - - 1
Local Authority (15) 8 - 2 3
Local coastal partnership (7) 2 - - -
Local group (5) - - - 1
Other public sector (10) 1 2 - 3
Recreation / Tourism (7) 2 - - 1
Other (4) - - - 1
Total (124) 32 3 5 16

12.4 A number of reasons were provided in support of this proposal. For example, it was considered essential that the NMP guides Sectoral Marine Plans and provides an overview of spatial areas as sectoral plans are developed; that this will ensure marine planning is led by the NMP; that it will help with the integration of policies; or that it will enable a full understanding of the interactions between energy extraction technology and the marine environment. A respondent in the energy group noted that there could be benefit for sectoral plans to incorporate spatial information and suggested this could be trialled as a case study around the Pentland Firth and Orkney Waters. These are areas where there is already a stated intent to designate this as a Strategic Sea Area.

12.5 Another respondent in the energy sector noted:

"Yes - the NMP is a strategic document which appropriately identifies key aims for the country, and incorporating the high level spatial information from the sectoral plans will be useful in creating a hierarchical policy framework which can then be expanded upon in more focused, area specific plans. The NMP should clearly inform decisions regarding the precedence or presumption of one sector over another."

12.6 Another respondent in the academic/ scientific sector commented:

"The ongoing development of marine renewable energy should proceed with a full understanding of the interactions between energy-extraction technology and the marine environment, including local uses such as fishing, aquaculture, conservation etc. Scotland's NMP and the regional marine plans will be important in terms of reconciling the development of marine renewables with fair and balanced management of Scotland's seas. This will require developers to fully participate in dialogue with researchers during developmental projects, to ensure that targets for development are appropriate and the experiences of early development at, for example, the European Marine Energy Centre, are fully incorporated into future research and development."

12.7 A small number of respondents also noted that Sectoral Marine Plans should be seen as background information to the NMP rather than as stand-alone documents.

12.8 There were also a few requests, mainly from Local Authorities, for additional information in the NMP. This included an explanation of the nature of the spatial information provided, an explanation of the presumption in favour concept, an explanation of the role of Regional Marine Plans or clarification of how data management and decision making at a sectoral level would interact with marine planning. There was also a request for the NMP to state that there may be further development potential within the Plan Option areas for marine renewables, in that Regional Marine Plans should provide the opportunity for more analysis of development potential and allow local communities and other stakeholders to be included in this process.

12.9 Respondents who provided a qualified 'yes' response, tended to raise questions they needed to be addressed such as who would be responsible for providing up-to-date spatial information.

12.10 The small number of respondents who did not want to see spatial information for Sectoral Marine Plans incorporated in the NMP focused on the need for consistency between the NMP and Sectoral Marine Plans but felt it would be preferable if the NMP signposted organisations and provided links to the relevant documents rather than incorporating information within the NMP itself. A public sector organisation noted that because of the uncertain nature of many planned and possible developments, it would be too prescriptive to incorporate spatial information within the NMP.

12.11 A small number of respondents also referred to the need for greater consistency between land use planning and marine planning in terms of offshore renewables and noted the need for a greater link to be made between NPF3 and NMP or highlighted the need for integration across land use and marine planning.

12.12 Two respondents, a local group and an individual noted concerns from the visual impact of offshore renewables and the damage this could cause to the tourism sector.

Comments on Offshore Renewable Energy, Chapter 11

12.13 The next two questions then went onto ask respondents:

Question 24: Do you have any comments on Offshore Renewable Energy, Chapter 11?

Question 25: Are there alternative planning policies that you think should be included in this chapter?

12.14 As shown in table 12.2, 54 respondents provided commentary at Q24, although much of this commentary was suggestions for changes to wording in various sections of this chapter.

Table 12.2 Question 24: Do you have any comments on Offshore Renewable Energy?

Respondent group
Individuals (16) 5
Academic / scientific (7) 4
Aquaculture (5) 3
Energy (12) 6
Environment / conservation (9) 6
Fisheries (13) 4
Historic / Heritage (5) 3
Industry / transport (9) 3
Local Authority (15) 10
Local coastal partnership (7) 2
Local group (5) -
Other public sector (10) 4
Recreation / Tourism (7) 2
Other (4) 2
Total (124) 54

12.15 While a number of themes emerged, most appeared in small numbers of responses. A number of respondents simply noted their support for specific elements of the chapter.

12.16 Better integration between onshore and offshore renewables was an issue raised by a number of respondents. For example, that offshore developments also need a supportive onshore infrastructure and development to help support the growth of the offshore renewable sector. As one Local Authority noted:

"Onshore locations which have good existing connections to the national grid… are likely to be chosen as connection points for power generated by offshore renewables. The onshore infrastructure required for connection to the national grid is very large and the impact of these buildings may be considerable. Due to geography, geology and economic factors, the landing points for transmission cables of power generated by offshore renewables are likely to be in demand …. Care must be taken to allow landing points for all developers. There is a need to consider both offshore and onshore elements together rather than in isolation."

12.17 Another respondent noted the need to ensure the integration of land use and marine planning systems, policies processes and practice and commented:

"There is considerable overlap between land use and marine planning systems in the consideration and consenting of offshore renewable energy developments. The onshore implications and developments associated with any offshore development must be a consideration. Both onshore and offshore elements of a development must be considered together, not in isolation. This requires the integration of land use and marine planning systems, policies, processes and practice to avoid duplication and ensure that appropriate weight is given in the decision making process to the onshore development."

12.18 Allied to the need for integration across land use and marine planning systems, some Local Authorities noted the need for better links with N- RIP and NPF3, with some comments relating to the need for consistency across the mapping of issues.

12.19 Another key theme emerging, albeit from a relatively small number of respondents was for the need for an approach to marine planning that takes sustainability into account. Most respondents making this comment were in the environment/ conservation sector. Other issues raised primarily by those in the environment/ conservation sector and a few in the historic/ heritage sector included suggestions for careful assessment of proposals for new developments and the cumulative impacts of these so that there is no harm caused to the environment. They also had a concern that increased interconnection activity could result in more applications for new developments in important wildlife areas and that the planning system will need to be able to respond appropriately to each. There was a suggestion from a Local Authority for the need to make use of appropriate Historic Environment Records.

12.20 The issue of maintaining a balance between new offshore developments and existing sectors was also raised by a number of respondents in the fisheries sector. They noted concerns over the impacts of installations on fisheries and the need for mitigation measures to counteract these. Three fisheries organisations suggested that there is a need to consider compensation for displaced fishing activity. One public sector organisation noted that the assessment and management of cumulative impacts is very challenging for offshore renewable developments and that this needs to be better addressed in the NMP. An organisation in the environment/ conservation sector commented that;

"New offshore renewables developments and the extensive grid infrastructure that they will require to support them (both off and onshore) are likely to have a significant impact on Scotland's habitats and species, the historic environment and onshore on Scotland's landscapes. Strategic Environmental Assessment, Habitat Regulations Assessment and Environmental Impact Assessment will be crucial in determining where these developments should be located with least environmental impact."

12.21 A small number of respondents referred to the need for consultation across a wide range of audiences. A Local Authority asked that planning authorities are involved in discussions with developers; an organisation in the fisheries sector requested more collaborative planning for the siting of marine renewable developments at a local level; an individual asked that communities are involved in discussions over proposals for new windfarms. Two energy companies noted there are opportunities for offshore renewables to work in tandem with other sectors to maximise benefits for all.

12.22 There were a few calls for more research to be undertaken. One Local Authority noted:

"Further research is required to determine the effects of the electro magnetic fields surrounding transmission cables on nearby marine life. Other users of the sea e.g. fishermen, may see a drop in number and size of fish. Fewer fish being caught may then have a knock on effect on on-shore businesses e.g. fish markets, fish processors and transport companies, many of whom are economically fragile communities."

12.23 An organisation in the aquaculture sector suggested research to ascertain the potential for co-locating offshore renewable developments and offshore aquaculture developments and noted there could be benefits in terms of marine spatial planning in Scotland as a result of this.

12.24 Only 19 respondents commented at question 25 and their responses are outlined in the following bullet points. While the question focused on alternative policies that should be included in this chapter, three respondents provided comments on the objectives outlined at the beginning of this chapter and these are also provided below.

Comments on objectives

  • Include specific reference to facilitation of new and additional port facilities for the manufacture of offshore renewable infrastructure in Scottish waters (this is in line with the N- RIP strategy and west coast clustering);
  • A key objective is missing for integrating marine developments with required onshore infrastructure including grid infrastructure, port infrastructure, housing etc. The Recreation & Tourism chapter includes such an objective, which is considered even more important for the Renewables sector;
  • Suggest including an objective around future telecommunications cables, for example supporting the roll out of high speed broadband in the Highlands and Islands.

Additional Policies recommended for inclusion in this chapter

  • Continued commitment to gather data to support the development of offshore renewables;
  • Acknowledgement of the range of technologies, scale of developments and corresponding level of impact to support a proportionate marine licensing requirement;
  • Conflict resolution / mediation;
  • Continued review and refinement of the licensing requirements to ensure that they are current and fit for purpose in terms of application;
  • Supporting offshore infrastructure should be highlighted in the plan, (which may be separately developed from the renewable energy installation) and should also have a presumption in favour for development;
  • A policy promoting the role of monitoring & research to help drive low-risk commercialisation of the offshore wind, wave and tidal sectors. It should be clear that there is an expectation upon both government and developers to contribute to such a programme of monitoring and research;
  • An additional planning policy is needed which states the requirement for close integration and joint working between marine and land use planning authorities to ensure consideration of both marine and onshore requirements;
  • A separate policy encouraging co-location of renewable energy projects and other activities ( e.g. aquaculture) would be helpful (this may be most appropriate at the general level, to highlight the opportunities through co-location, rather than distinct sectoral ambitions that result in conflict);
  • There is no policy that clearly identifies the need to take account of the likely socio-economic impacts from marine renewable development or to the importance of considering landscape impact, which is a critical economic asset to many of our communities;
  • There is no policy which reflects the need to carefully examine the cumulative impact of multiple developments;
  • It is essential that Scottish Government identify specific sites for onshore infrastructure for Offshore Renewable Energy in order to guide investment and provide a framework for delivery of ambitious renewable energy generation targets;
  • A separate policy should be developed which emphasises the importance of delivering grid connections and how this can be achieved, particularly to the North Isles. Policy Renewable 6 addresses consenting for grid connections but does not emphasis the strategic importance of grid connection to the development of the entire marine renewable energy sector;
  • A policy or statement detailing what will be set out in the regional marine plans with regard to this section;
  • Policy of not using Offshore Renewable Energy if the same energy can be made more cheaply, sustainably and effectively elsewhere.

12.25 Two respondents made a recommendation for an additional objective for this chapter of the NMP:

  • There is a recognition that coordinated national, regional and project specific environmental monitoring is required to better inform marine spatial planning and decision making. An additional objective encouraging industry-wide monitoring packages that are standardised where appropriate and integrate and coordinate government, industry and project level programmes would provide a driver and focus to prioritise and deliver much needed monitoring. This monitoring data will ultimately contribute to the sustainable development of the offshore renewables industry by informing decision makers, increasing certainty and reducing risk.